Get involved in the annual scheme change management cycle!
The Single Euro Payments Area () payment schemes, as set out in the Credit Transfer () and Direct Debit () Rulebooks, evolve based on a transparent change management process adhered to by the European Payments Council (). The principles governing the evolution of the Schemes are set out in section three of the Scheme Management Internal Rules (see 'related links' below). The first step in the annual scheme change management cycle is the introduction of suggestions for changes to the schemes by any interested party.
The deadline to submit suggestions for changes to the and Rulebooks in the 2012 scheme change management cycle is 29 February 2012. The template and contact information required to submit suggestions for changes to the Schemes is provided at the bottom of this article (see 'related links' below).
In consideration of the suggestions received, the Payments Working Group (SPS WG) develops a single change request document per rulebook (the Rulebook, the Core Rulebook and the Business to Business Rulebook). The preparation of the change request documents involves analysis of the suggestions for changes received including a cost-benefit analysis, dialogue with the initiator and, if appropriate, market research. Based on this analysis, the SPS WG decides whether to accept a suggestion for change into the change management process or not. Initiators of any suggestions for changes are notified of the decision taken by the SPS WG. All suggestions to modify the rulebooks received by the - irrespective of whether they have been accepted into the change management process - are published on the Website, permitting such a list to be openly viewed by all stakeholders.
The change request for the current year will be released for a three-month public consultation in May 2012.
Taking into account comments received during the consultation, the SPS WG will complete a change proposal per rulebook for approval by the Plenary in September 2012. As a result of this annual change cycle, the and Schemes incorporate numerous features introduced by end users.
Figure 1: Annual Scheme Rulebook Change and Release Management Cycle
The Regulation transfers the responsibility for scheme management to the European Commission
It remains the 's objective to ensure that the and Rulebooks evolve in response to proven market needs, based on a predictable release schedule. The must, however, clarify that it can no longer be held accountable in this regard.
The European Union (EU) legislator will shortly adopt the 'Regulation Establishing Technical Requirements for Credit Transfers and Direct Debits in Euros' (the Regulation). The technical requirements set out in the Annex to the Regulation apply to Union-wide euro credit transfer and direct debit schemes; i.e. the and Schemes. The Regulation also gives power to the European Commission to amend the technical requirements at its sole discretion. Moving forward, the will be under the legal obligation to align the and Rulebooks with the technical requirements as amended by the European Commission and according to the timelines mandated by the European Commission.
When amending the technical requirements defined in the Annex to the Regulation, the European Commission is under no formal obligation to consider the preferences of payment service users as identified through public -wide consultations carried out by the . The European Commission however, places great reliance on the advice of Brussels-based lobbying organisations, which speak on behalf of the demand side. The safest bet now for bank customers seeking to channel their requirements into the Schemes is therefore to lobby via their European lobbying group.
Important notice to all stakeholders: impact of the Regulation on and Rulebook Release Management
To ensure planning security for all market participants, publication of new rulebook versions by the is based on a predictable rulebook release management cycle. In accordance with best industry practice, payment service providers and their suppliers have a one-year lead time to address rulebook updates prior to such updates taking effect. The publishes updated versions of the rulebooks once annually in November of each year. The updated versions of the rulebooks then take effect in the third week of November the following year to allow for alignment with SWIFT message releases.
Moving forward, the may be required however, to adapt the rulebook release schedule at short notice to ensure compliance with technical requirements set out in the Annex to the Regulation as amended by the European Commission.
All market participants obliged to adapt systems and operations with the technical requirements applicable to the and Schemes decreed by the European Commission, would greatly appreciate it if the regulators were able to make specific information on the principles and timelines governing the further evolution of the schemes available. To date, the European Commission has however not yet publicly communicated on the matter.
To learn more about the general principles governing the procedure to be applied by the European Commission to determine and amend technical requirements, refer to the article 'The New European Decision-Making Landscape: How the European Commission Rules Through Delegated Acts' (see 'related articles in this issue' below).
Javier Santamaría is the Chair of the Payment Schemes Working Group.
Related articles in this issue:
SEPA Regulation: European Legislator Mandates Migration to SEPA by 1 February 2014 in the Euro Area and Transfers the Responsibility for SEPA Scheme Management to the European Commission. EPC Chair comments on the new regulatory reality governing the integration of the euro payments market
The New European Decision-Making Landscape: How the European Commission Rules Through 'Delegated Acts'. SEPA Regulation empowers the European Commission to mandate technical requirements applicable to SEPA payment schemes
Related articles in previous issues:
Brave New World: the European Commission Becomes the SEPA Scheme Manager. The EPC offers the regulator some insight on scheme development and rulebook release management ( Newsletter, Issue 12, October 2011)
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